An animal rights group asserts in habeas suit that scientific evidence supports “legal personhood” for a chimpanzee named Tommy.

The suit filed on Monday by the Nonhuman Rights Project argues that chimps have complex cognitive abilities, including a “concept of their past and future,” the Wall Street Journal Law Blog (sub. req.), the New York Times and Reuters report.

The suit, filed in Fulton County Court in New York, says courts in the state have granted legal personhood to domestic animals that are trust beneficiaries. It also says corporations have been granted rights though they aren’t human.

According to the suit, Tommy is being held in a “small, dank, cement cage in a cavernous dark shed” by two humans who keep exotic animals at their used trailer lot. The Nonhuman Rights Project has set up a trust for Tommy and is asking the court to order Tommy to be placed in a sanctuary.

The group plans to file two more suits this week on behalf of another chimp held by private owners and two chimps being housed at Stony Brook University for a research project.

Patrick Lavery is one of Tommy’s owners. He told the Times he rescued the chimp from another home where he was poorly treated for 30 years, and he now lives in a large cage with lots of toys. Lavery says he has been unable to find a sanctuary with room for the animal.

Lawyer Steven Wise leads the Nonhuman Rights Project. “These are the first cases in an open-ended, strategic litigation campaign,” he told Reuters. “We’re just going to keep filing suits.”